DCT

3:25-cv-02115

Patent Armory Inc v. Unisys Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-02115, N.D. Tex., 08/08/2025
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Texas because Defendant maintains an established place of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services infringe five U.S. patents relating to intelligent call routing and auction-based systems for matching entities.
  • Technical Context: The patents-in-suit relate to technologies for optimizing resource allocation in communications systems, particularly call centers, a domain focused on maximizing operational efficiency and customer satisfaction.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2002-03-07 Priority Date for ’979 and ’253 Patents
2003-03-07 Priority Date for ’420 and ’086 Patents
2006-04-03 Priority Date for ’748 Patent
2006-04-04 ’979 Patent Issued
2007-09-11 ’253 Patent Issued
2016-09-27 ’086 Patent Issued
2019-03-19 ’420 Patent Issued
2019-11-26 ’748 Patent Issued
2025-08-08 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,237,420: Method and system for matching entities in an auction (Issued Mar. 19, 2019)

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inefficiencies of traditional call center management, which often relies on simple rules like first-in, first-out call queuing or static skill assignments. This can lead to suboptimal pairings, such as routing a customer to an "under-skilled agent" who cannot resolve the issue or an "over-skilled agent" whose expertise is wasted on a simple query (U.S. Patent No. 10,237,420, col. 4:35-60).
  • The Patented Solution: The invention proposes a system that treats the matching of a first entity (e.g., a caller) with a second entity (e.g., a call center agent) as an economic optimization problem. It defines parameters for each entity and performs an "automated optimization" that considers not only the direct value of a match (its "economic surplus") but also the "opportunity cost" of making that second entity unavailable for other potential matches (’420 Patent, Abstract). This optimization is designed to be performed within the communications switching architecture itself, rather than by a separate high-level system (’420 Patent, col. 18:9-24).
  • Technical Importance: This approach seeks to enable more dynamic and efficient resource allocation in high-volume communication environments by moving beyond simple queuing to a system that models the economic consequences of each potential connection in real time (’420 Patent, col. 1:18-24).

Key Claims at a Glance

  • The complaint does not identify which specific claims of the ’420 Patent are asserted, instead incorporating by reference claim charts that were not provided with the complaint (Compl. ¶15, ¶17-18).

U.S. Patent No. 10,491,748: Intelligent communication routing system and method (Issued Nov. 26, 2019)

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of balancing competing goals in a call center: providing high-quality customer service while making efficient use of resources. It notes the limitations of static routing rules and the difficulty of scheduling agents with varied skill sets to meet fluctuating demand (’748 Patent, col. 2:25-40, via parent document).
  • The Patented Solution: The invention is a communications routing system that represents both communication sources (e.g., callers) and targets (e.g., agents) by their "predicted characteristics," each having an associated "economic utility." The system determines an optimal routing path by "maximizing an aggregate utility" for all linkages, effectively treating the routing decision as a multi-factorial optimization problem that can account for factors like agent training and long-term call center goals (’748 Patent, Abstract; Fig. 1).
  • Technical Importance: The technology aims to provide a more holistic and intelligent routing framework that can optimize for complex, long-term business objectives, such as agent development, rather than just immediate transactional efficiency (’748 Patent, Fig. 1, steps 311-312).

Key Claims at a Glance

  • The complaint does not identify which specific claims of the ’748 Patent are asserted, referring only to claims identified in an unprovided exhibit (Compl. ¶21, ¶26-27).

U.S. Patent No. 7,023,979: Telephony control system with intelligent call routing (Issued Apr. 4, 2006)

  • Technology Synopsis: This patent addresses the problem of inefficient call routing in telephony systems. It describes a solution where incoming communications are classified, matched against a database of agent skills and skill weights, and routed based on an "optimum agent selection" computed by a processor considering cost-benefit factors, with the routing being directly controlled by the system (’979 Patent, Abstract).
  • Asserted Claims: Not specified in the complaint (Compl. ¶30).
  • Accused Features: Not specified beyond a general allegation of infringement (Compl. ¶30).

U.S. Patent No. 7,269,253: Telephony control system with intelligent call routing (Issued Sep. 11, 2007)

  • Technology Synopsis: This patent describes a telephony control system aimed at improving upon simple skill-based routing. The patented solution involves a combinatorial optimization of call assignments, considering factors such as predicted agent availability and a cost-benefit analysis to determine the most effective matching of callers to agents in a dynamic call center environment (’253 Patent, Abstract).
  • Asserted Claims: Not specified in the complaint (Compl. ¶36).
  • Accused Features: Not specified beyond a general allegation of infringement (Compl. ¶36).

U.S. Patent No. 9,456,086: Method and system for matching entities in an auction (Issued Sep. 27, 2016)

  • Technology Synopsis: This patent discloses a method for matching entities by framing the selection process as an auction. The system performs an automated optimization that evaluates the "economic surplus" of a potential match while also factoring in the "opportunity cost" of making one entity unavailable for other potential matches, thereby seeking a globally optimal allocation of resources (’086 Patent, Abstract).
  • Asserted Claims: Not specified in the complaint (Compl. ¶42).
  • Accused Features: Not specified beyond a general allegation of infringement (Compl. ¶42).

III. The Accused Instrumentality

  • Product Identification: The complaint does not identify any specific accused products, methods, or services by name (Compl. ¶15, ¶21, ¶30, ¶36, ¶42).
  • Functionality and Market Context: The complaint refers generally to "Exemplary Defendant Products" that are allegedly identified in claim chart exhibits attached to the complaint (Compl. ¶15, ¶17). However, these exhibits were not provided. Consequently, the complaint provides no factual description of the functionality or market context of any accused instrumentality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain any substantive factual allegations of infringement in its main body. For each of the five patents-in-suit, the complaint alleges direct infringement by incorporating by reference a series of exhibits (Exhibits 6-10) that purportedly contain claim charts comparing the patent claims to the "Exemplary Defendant Products" (Compl. ¶17-18, ¶26-27, ¶32-33, ¶38-39, ¶47-48). As these exhibits were not provided, a detailed analysis of the infringement allegations is not possible.

  • Identified Points of Contention:
    • Pleading Sufficiency: A threshold legal question may be whether the complaint's complete reliance on incorporating non-provided exhibits for its substantive infringement allegations satisfies the plausibility pleading standards established by federal court precedent.
    • Technical Application: Should the case proceed, a central technical question will be whether the concepts described in the patents—which are heavily grounded in the context of telephony call centers—can be shown to apply to the specific architecture and operation of the as-yet-unidentified accused products or services.

V. Key Claim Terms for Construction

The complaint does not identify any specific asserted claims from any of the five patents-in-suit. This precludes an analysis of key claim terms that may be central to the dispute.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for the ’748 and ’086 Patents. The allegations are based on Defendant allegedly distributing "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the patents (Compl. ¶24, ¶45). The complaint alleges that this inducement has occurred at least since the Defendant was served with the complaint and corresponding claim charts (Compl. ¶25, ¶46).
  • Willful Infringement: While the complaint does not use the term "willful," it lays the groundwork for a claim of post-filing willfulness regarding the ’748 and ’086 Patents. It alleges that "service of this Complaint, in conjunction with the attached claim charts and references cited, constitutes actual knowledge of infringement" and that Defendant continued to infringe despite this alleged knowledge (Compl. ¶23-24, ¶44-45).

VII. Analyst’s Conclusion: Key Questions for the Case

At this initial stage, the case appears to turn on foundational procedural and definitional issues rather than specific technical disputes.

  • A core issue will be one of pleading sufficiency: Does a complaint that contains no factual infringement allegations in its body and instead relies exclusively on incorporating by reference unprovided exhibits meet the legal standard for plausibly stating a claim for patent infringement?
  • A second key question will be one of technological scope: Assuming the case moves forward and specific products are identified, the dispute will likely center on whether the patented methods, which are described in the context of optimizing real-time voice call routing, can be construed to cover the functionalities of Defendant's presumably different enterprise software or service offerings.
  • Finally, an evidentiary question will be one of intent: For the indirect and potential willfulness allegations, the case may explore what specific actions, such as the continued distribution of user manuals for accused products after receiving the complaint, are sufficient to establish the knowledge and intent required for these claims.